Singapore legislation

Regulation 11

of Multinational Enterprise (Minimum Tax) Regulations 2024

Regulation 11

FANIL adjusted to be before tax

The FANIL of a constituent entity of an MNE group for a financial year must be adjusted by adding back any positive amounts and excluding any negative amounts of tax expense (including a deferred tax expense) in respect of the following, as reflected in the FANIL:

(a)

a covered tax (whether or not the income to which the tax relates is excluded from its GloBE income or loss);

(b)

any MTT, or any qualified IIR;

(c)

any DTT, or any qualified domestic minimum top‑up tax;

(d)

a qualified UTPR;

(e)

any disqualified refundable imputation tax (as defined in paragraph 1(7) of the First Schedule to the Act);

(f)

any tax payable by a life insurer in respect of amounts accruing to or paid to policyholders.